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Assessment of Temporary Assignments Needed' which was released on 
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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

February 2009: 

Bureau Of Prisons: 

Written Policies on Lateral Transfers and Assessment of Temporary 
Assignments Needed: 

Bureau of Prisons: 

GAO-09-141: 

GAO Highlights: 

Highlights of GAO-09-141, a report to congressional requesters. 

Why GAO Did This Study: 

The Department of Justice’s Federal Bureau of Prisons (BOP) is 
responsible for the custody and care of more than 202,000 federal 
offenders with approximately 35,000 employees, almost half of whom are 
correctional officers, dispersed across BOP’s 114 correctional 
facilities in 6 regions. In response to a request, GAO identified 
whether BOP had policies and procedures and how it assessed the 
management of those policies and procedures for (1) employee-requested 
lateral transfers of BOP employees between correctional facilities and 
(2) day-to-day changes in correctional services or temporary 
assignments of BOP employees within a correctional facility. GAO 
reviewed available documentation on BOP’s policies and procedures on 
lateral transfers and temporary assignments. GAO also interviewed 
officials from BOP’s central and regional offices and seven facilities 
selected on the basis of the number of staff; at least one facility was 
selected from within each of BOP’s six regions. 

What GAO Found: 

BOP does not have written policies and procedures on lateral transfers 
of staff. Each correctional facility evaluates requests for lateral 
transfers on a case-by-case basis. Typically, when an employee requests 
a lateral transfer to another facility, the warden at the employee’s 
current facility determines whether to forward the request to the 
desired facility’s warden. The processes for requesting a lateral 
transfer and the criteria for forwarding, granting, or denying such 
requests varied across the facilities GAO reviewed, and generally no 
documentation on decisions reached or actions taken was maintained. 
Further, BOP does not systematically review decisions concerning these 
requests at any level. As a result, BOP cannot determine the number of 
requests for lateral transfers, the outcome of these requests, or 
whether requests were handled consistently within or among facilities. 
GAO has previously reported that agencywide policies and procedures 
help ensure consistent treatment of staff when agencies have 
geographically dispersed locations. Other Department of Justice law-
enforcement components have written policies, procedures, and a review 
process concerning requests for lateral transfers. 

Unlike lateral transfers, BOP has written policies and procedures on 
how facilities are to temporarily assign staff to fill in for absences 
or to meet other needs that arise in a facility. However, BOP has not 
systematically assessed how facilities are managing temporary 
assignments. As part of a cost-reduction strategy affecting temporary 
assignments, in 2005, BOP designated mission critical posts, that is, 
assignments that were deemed essential for the safe and secure 
operations of its facilities and that would be vacated only in rare 
circumstances. The mission critical post initiative was intended to 
reduce facilities’ reliance on overtime and non-correctional services 
staff, who had typically been used for temporary assignments. A 
memorandum from the Assistant Director of Correctional Programs 
described how each facility was to gather information for 6 months on 
overtime and staffing under the mission critical post initiative and 
how BOP would evaluate the effectiveness of the initiative. However, 
BOP conducted no such evaluation. BOP officials also generally do not 
review temporary assignments at any level, including the effect of 
leaving mission critical posts unassigned. 

According to the Standards for Internal Control in the Federal 
Government, federal agencies are to employ internal control activities, 
such as top-level review, to help ensure that management’s directives 
are carried out and to determine if agencies are effectively and 
efficiently using resources. Without assessing its mission critical 
post initiative and data on temporary assignments, BOP does not know 
whether it is efficiently and effectively using staff for temporary 
assignments or achieving the desired cost savings. Also, without 
reviewing the effect of leaving mission critical posts unassigned, BOP 
cannot assess the effect, if any, of unassigned posts on the safety and 
security of its facilities. 

What GAO Recommends: 

GAO recommends that BOP (1) develop and implement specific policies and 
procedures for administering employee requests for lateral transfers 
and (2) systematically assess temporary assignments. BOP agreed with 
GAO’s findings, disagreed with the first recommendation, and agreed 
with and plans to take action on the second. GAO continues to believe 
written policies would help ensure consistency across BOP. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-141]. For more 
information, contact George H. Stalcup at (202) 512-9490 or 
stalcupg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

BOP Lacked Written Policies and Procedures for Processing Requests for 
Lateral Transfers: 

BOP Has Policies and Procedures for Staffing Temporary Assignments but 
Has Not Systematically Assessed Their Use: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: BOP's Correctional Services Roster Assignment and 
Temporary Assignment Process: 

Appendix III: Analysis of Correctional Services Daily Rosters at 
Selected BOP Facilities: 

Appendix IV: Comments from the U.S. Department of Justice: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Estimated Average Daily Number of Special Assignments and 
Number Unassigned for Selected BOP Facilities, 2007: 

Figures: 

Figure 1: Locations of BOP Facilities and Regions and the Facilities in 
Our Review: 

Figure 2: Options for Staffing a Temporary Assignment: 

Figure 3: Estimated Average Daily Percentage of Unassigned Mission 
Critical Posts at Selected BOP Facilities, 2007: 

Figure 4: Estimated Average Daily Percentage of Mission Critical Posts 
Filled with Overtime at Selected BOP Facilities, 2007: 

Figure 5: Estimated Average Daily Percentage of Mission Critical Posts 
Filled with Non-Correctional Services Staff at Selected BOP Facilities, 
2007: 

Figure 6: Estimated Average Daily Percentage of Special Assignments 
Filled with Overtime at Selected BOP Facilities, 2007: 

Figure 7: Estimated Average Daily Percentage of Special Assignments 
Filled with Non-Correctional Services Staff at Selected BOP Facilities, 
2007: 

Abbreviations: 

AFGE: American Federation of Government Employees: 

BOP: Bureau of Prisons: 

EEOC: Equal Employment Opportunity Commission: 

FCC: federal correctional complex: 

FCI: federal correctional institution: 

FMFIA: Federal Managers' Financial Integrity Act of 1982: 

NFC: National Finance Center: 

OPM: Office of Personnel Management: 

USP: United States Penitentiary: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

February 25, 2009: 

The Honorable John Conyers, Jr. 
Chairman: 
The Honorable Lamar Smith: 
Ranking Member: 
Committee on the Judiciary: 
House of Representatives: 

The Honorable F. James Sensenbrenner, Jr. 
House of Representatives: 

The Department of Justice's Federal Bureau of Prisons (BOP) is 
responsible for the custody and care of more than 202,000 federal 
offenders, up from fewer than 25,000 in 1980. According to BOP, more 
than 166,000, or approximately 82 percent, of these inmates are 
confined in BOP's 114 correctional facilities and detention centers of 
various security levels.[Footnote 1] Responsible for the custody and 
care of these inmates are approximately 35,000 BOP employees. 

As agreed, this report responds to your request that we review BOP's 
management of permanent reassignments and temporary assignments of BOP 
employees at its facilities. Specifically, our objectives were to 
identify whether BOP had policies and procedures and how it assessed 
the management of those policies and procedures for (1) permanent 
reassignments of BOP employees between correctional facilities and (2) 
temporary assignments of BOP employees within a correctional facility. 
For purposes of this report, permanent reassignments, which BOP refers 
to as lateral transfers, are employee-requested transfers to other BOP 
facilities that do not involve a promotion or demotion.[Footnote 2] 
Temporary assignments are day-to-day changes in correctional services 
assignments within BOP facilities, which are made for a variety of 
reasons, including (1) illness or other absences of staff or (2) 
special assignments (i.e., to meet needs that arise in a facility, not 
including regularly assigned posts).[Footnote 3] 

As part of our review, we selected seven BOP facilities, which included 
five separately located facilities and two federal correctional 
complexes (FCC).[Footnote 4] We selected facilities with the largest 
number of staff, with at least one facility from within each of BOP's 
six regions, and included low-and medium-security federal correctional 
institutions (FCI) and high-security United States Penitentiaries 
(USP). We excluded administrative facilities from our review. The 
facilities selected were USP Lee in Virginia, USP Hazelton in West 
Virginia, USP Pollock in Louisiana, FCI Sheridan (medium) in Oregon, 
FCI Fort Dix (low) in New Jersey, FCC Coleman (consisting of four 
facilities--two high-security, one medium-security, and one low- 
security) in Florida, and FCC Terre Haute (consisting of two 
facilities, a high-security and a medium-security) in Indiana. We 
conducted a site visit to USP Hazelton and interviewed officials at the 
other facilities by video conference. 

To assess BOP's management of lateral transfers and temporary 
assignments, we reviewed available documentation on BOP's written 
policies and procedures for such transfers and assignments, the 
implementation of those policies and procedures, and how BOP has 
assessed the implementation of those policies and procedures. We also 
reviewed the lateral transfer policies of four other law enforcement 
Justice components--the Federal Bureau of Investigation; the U.S. 
Marshals Service; the Bureau of Alcohol, Tobacco, Firearms, and 
Explosives; and the Drug Enforcement Administration. For lateral 
transfers, we interviewed officials from BOP's Human Resources and 
Program Review divisions; each of its six regional offices; its 
Consolidated Employee Service Center in Grand Prairie, Texas; and the 
selected facilities. We also interviewed representatives of the 
American Federation of Government Employees Council of Prison Locals 
(AFGE). For temporary assignments, we reviewed BOP's policies and 
procedures related to correctional services' roster assignments. For 
each facility in our review, we analyzed a stratified random sample of 
60 hard-copy correctional services daily rosters, 5 per month, for 
calendar year 2007 and estimated the extent to which the facilities in 
our review used temporary assignments. For FCC Coleman, which uses 
separate daily rosters to assign staff at each of its four facilities, 
we reviewed the separate rosters from each facility for the same 60 
days. For FCC Terre Haute, which uses a consolidated roster to assign 
staff throughout the complex, we reviewed the consolidated daily roster 
for the 60 days. We determined that the data from the hard-copy daily 
rosters were sufficiently reliable for purposes of this report. We also 
interviewed individuals from BOP's Correctional Programs and Program 
Review divisions, its Office of Research and Evaluation, each of its 
six regional offices, the selected facilities, and representatives of 
AFGE. See appendix I for a more detailed discussion of our scope and 
methodology. 

We conducted this performance audit from August 2007 to January 2009, 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Results in Brief: 

BOP does not have written policies and procedures on lateral transfers 
of staff. Correctional facilities generally evaluate requests for 
lateral transfers on a case-by-case basis. Typically, when an employee 
requests a lateral transfer to another facility, the warden at the 
employee's current facility determines whether to forward the request 
to the desired facility's warden. However, the processes for requesting 
a lateral transfer and the criteria for forwarding, granting, or 
denying such requests varied across the facilities we reviewed, and 
generally documentation on decisions reached or actions taken was not 
maintained. Further, BOP does not systematically review lateral 
transfers at any level. BOP officials told us that they did not think 
written policies on lateral transfers were necessary because of the 
infrequency of such requests and had not considered lateral transfers a 
high-risk area necessitating review. Without documented procedures or 
documentation on transfers made, BOP cannot determine the number of 
requests for lateral transfers, the outcome of these requests, or 
whether requests were handled consistently within or among facilities. 
We have previously reported that agencywide policies and procedures 
help ensure consistent treatment of staff, particularly when agencies 
have geographically dispersed locations. According to an official from 
the Office of Personnel Management's Strategic Human Resource Policy 
Division, documentation of consistent treatment would also provide 
support for an agency's decision-making process when there are claims 
of favoritism and help an agency to avoid perceptions of inconsistent 
treatment. Other Justice law-enforcement components have policies, 
procedures, and a review process covering lateral transfers. 

Unlike lateral transfers, BOP has written policies and procedures on 
how facilities are to temporarily assign staff. However, BOP has not 
systematically assessed how facilities are managing temporary 
assignments. As part of a cost-reduction strategy affecting temporary 
assignments that began in 2004, BOP designated mission critical posts 
in 2005, that is, assignments that were deemed essential for the safe 
and secure operations of its facilities and that would be vacated only 
in rare circumstances. The mission critical post initiative was 
intended to enable facilities to reduce reliance on overtime and non- 
correctional services staff, who had typically been used for temporary 
assignments. A memorandum from the Assistant Director of Correctional 
Programs described how each facility was to gather information on 
overtime and staffing over a 6-month period and how BOP would evaluate 
the effectiveness of the mission critical post initiative. However, BOP 
conducted no such evaluation, and BOP officials could not explain why 
the evaluation was not conducted. According to the Standards for 
Internal Control in the Federal Government, federal agencies are to 
employ internal control activities, such as top-level review, to help 
ensure that management's directives are carried out and to determine if 
agencies are effectively and efficiently using resources.[Footnote 5] 
BOP's Management Control and Program Review Manual states that BOP is 
to maintain a system of management controls that enables managers to 
assess program performance regularly. Further, in addition to not 
having evaluated the mission critical post initiative, BOP officials 
generally do not review temporary assignments, including the effect of 
leaving mission critical posts unassigned. Because BOP's computerized 
roster management system does not produce summary data on temporary 
assignments, the only way currently to assess how BOP is temporarily 
assigning staff would be to manually review daily rosters. Without 
evaluating its mission critical post initiative or routinely analyzing 
data on temporary assignments, BOP does not know whether it is 
efficiently and effectively using staff for temporary assignments or 
achieving the desired cost savings. Also, without reviewing the effect 
of leaving mission critical posts unassigned, BOP cannot assess the 
effect, if any, of unassigned posts on the safety and security of its 
facilities. 

We recommend that the Attorney General direct the Director of BOP to 
(1) develop and implement specific policies and procedures for 
administering employee requests for lateral transfers, including 
providing for the collection of data on such requests and their 
outcomes and the development of a system of oversight, and (2) 
systematically assess temporary assignments to ensure that BOP is 
meeting the objectives of the mission critical post initiative and 
effectively and efficiently using resources. 

We provided the Attorney General with a draft of this report for review 
and comment. In his written comments on behalf of the Attorney General, 
the Director of BOP agreed with our findings on the first 
recommendation but disagreed with the recommended action because BOP 
would have to devote resources to developing policies and procedures 
and maintaining such a program. In addition, BOP perceived our 
recommendation as elevating the process to a central office function. 
Instead, BOP plans to "encourage a practice to have locations post a 
vacancy announcement on USAJobs before filling local vacancies." We 
continue to believe that without written policies and procedures for 
managing lateral transfers, BOP cannot ensure that staff are being 
consistently treated when requesting lateral transfers. Regarding our 
second recommendation, the Director agreed and stated that BOP will 
conduct a systematic assessment of correctional services mission 
critical post use and conduct regularly scheduled reviews of 
institutions to determine whether it is meeting its mission critical 
post initiative and effectively and efficiently using resources. 

Background: 

BOP consists of a headquarters and six regional offices--Mid-Atlantic, 
North Central, Northeast, South Central, Southeast, and Western--that 
directly oversee the operations of its 114 facilities within their 
respective geographic regions of the country. BOP operates facilities 
of different security levels--minimum, low, medium, and high, which 
respectively have increasing security features, inmate to staff ratios, 
and control of inmate movement, and administrative, which have special 
missions, such as the treatment of inmates with serious or chronic 
medical problems. Some BOP facilities are part of BOP's 13 FCCs, which 
consist of two or more facilities colocated on property that is 
contiguous. BOP facilities are given a security designation based on 
the level of security and staff supervision the facility is able to 
provide. Figure 1 shows the locations of BOP facilities and regions and 
the facilities in our review. 

Figure 1: Locations of BOP Facilities and Regions and the Facilities in 
Our Review: 

[Refer to PDF for image] 

This figure is a map of the United States depicting the locations of 
BOP facilities and regions and the facilities in our review, as 
follows: 

Region: Northeast; 
Facility included in review: FCI Ft. Dix, New Jersey. 

Region: Mid-Atlantic; 
Facility included in review: USP Hazelton, West Virginia; USP Lee, 
Virginia. 

Region: Southeast; 
Facility included in review: FCC Coleman, Florida. 

Region: North Central; 
Facility included in review: FCC Terre Haute, Indiana. 

Region: South Central; 
Facility included in review: USP Pollock, Louisiana. 

Region: Western; 
Facility included in review: FCI Sheridan, Oregon. 

Note: The total number of the facilities indicated on the map is less 
than 114 because some facilities are part of federal correctional 
complexes (FCC), which include more than one facility. For example, FCC 
Coleman consists of four facilities, and FCC Terre Haute consists of 
two facilities. 

[End of figure] 

Facilities are managed by a warden and other officials, including an 
executive assistant and associate warden who generally provide overall 
direction and implement policies. Each facility consists of various 
departments, including the correctional services department, which 
represents the largest segment of each facility. Correctional workers 
are responsible for the correctional treatment, custody, and 
supervision of criminal offenders. The captain is the head of the 
correctional services department and generally reports to the warden or 
associate warden. Lieutenants are generally responsible for the day-to- 
day staffing of correctional services and report to the captain or 
deputy captain. Non-correctional services staff include, among others, 
those assigned to health services, unit management, food services, and 
facility operations. 

According to BOP written responses, all facility staff receive the same 
initial core 5 weeks of training and 1 week of annual refresher 
training.[Footnote 6] BOP's Master Agreement with AFGE permits 
management to determine the internal security practices of the agency 
and take whatever actions may be necessary to carry out the agency 
mission during emergencies.[Footnote 7] According to BOP officials, the 
warden is permitted to use all facility staff (including non- 
correctional services staff, such as secretary, nurse, or dentist) for 
correctional services assignments during emergencies and at other 
designated times. One of BOP's published core values is that all 
employees are "correctional workers first," regardless of the specific 
position to which an individual is hired, and both correctional 
services staff and non-correctional services staff are responsible for 
the safety and security of the facility. 

BOP Lacked Written Policies and Procedures for Processing Requests for 
Lateral Transfers: 

BOP has no written policies for lateral transfers and provides no 
guidance to facilities on how to process requests for lateral transfers 
or criteria for granting such requests. Requests for lateral transfers 
are generally handled on a case-by-case basis, and the processes and 
criteria used for granting those requests varied across facilities in 
our review. Neither BOP nor most of the facilities reviewed maintained 
documentation or tracked data on lateral transfers and their outcomes 
and did not systematically review lateral transfers. We have previously 
reported that agencywide policies and procedures help ensure consistent 
treatment when agencies are geographically dispersed.[Footnote 8] Our 
review of the lateral transfer policies of four other Justice 
components showed that each had established written policies and 
procedures for lateral transfers. 

BOP Had No Written Policy for Lateral Transfers, and Processes and 
Criteria Used Varied Across Facilities and Regions: 

According to officials from BOP's Human Resources Division, BOP has no 
written policies and procedures for processing staff requests for 
lateral transfers. The officials said that BOP staff request lateral 
transfers because of a variety of personal reasons, including personal 
hardship, such as a sick family member, or a relocated spouse. At most 
of the facilities included in our review, officials told us staff 
generally requested a lateral transfer from their current facility to 
another location by submitting a memorandum through their warden to the 
warden at the desired location. According to a written response from 
BOP, this approach is informal and is at the discretion of both 
wardens. BOP provides no guidance to facilities on how to process such 
requests or criteria for granting them. In addition, because no written 
policies and procedures exist, BOP has no way of ensuring that staff 
are aware of how to request a lateral transfer. An official at one 
facility in our review said because no written policies exist, if an 
employee wanted to find out about how to obtain a lateral transfer, the 
employee would have to ask someone. BOP officials told us that they did 
not think written policies on lateral transfers were necessary because 
of the infrequency of such requests. 

Officials from the facilities in our review reported using different 
processes and criteria for lateral transfers. Officials from two 
facilities said their Employee Services Department, which is 
responsible for human resources functions, forwarded a memorandum from 
the employee to the warden at the desired facility, while officials 
from other facilities said their Employee Services Department had no 
role in receiving or forwarding requests for lateral transfers. 
Officials we interviewed from two facilities said that their wardens 
routinely approved reassignment requests going out of the facility, 
while others said requests would be considered individually on a case- 
by-case basis. Further, in accepting requests for incoming lateral 
transfers, officials from some facilities said the decision was based 
on a combination of budgetary, staffing, and work performance factors, 
while one facility official said he preferred not to approve lateral 
transfers of senior correctional officers, specifically those at the 
General Schedule grade 8, because of its affect on morale. 

BOP Did Not Monitor Requests for Lateral Transfers or Their Outcomes: 

BOP was unable to identify the number of staff who were laterally 
transferred because it did not maintain data on the manner in which 
employees are permanently reassigned. According to a BOP Human 
Resources Division official we interviewed, BOP's personnel database 
did not contain information by type of permanent reassignment, such as 
agency-initiated, application for announced vacancy, or lateral 
transfers. In fiscal year 2005, a total of 2,749 staff were permanently 
reassigned; in fiscal year 2006, 1,952; and in fiscal year 2007, 1,901. 
According to BOP officials, these numbers reflect the total number of 
staff successfully reassigned through all types of permanent 
reassignments; BOP could not isolate lateral transfers. In addition, 
these numbers did not include the number of staff who applied for or 
requested a reassignment and were denied. 

BOP did not require facilities to maintain any documentation of 
requests for lateral transfers, such as the original memorandum making 
a request or documents indicating whether requests were forwarded, 
approved, denied, or reasons for denial. Officials from most of the 
facilities in our review said their facilities retained the original 
employee request memorandum in some circumstances, but one official 
said the request memorandum was never retained. Without such 
documentation, BOP was not able to determine BOP-wide the number of 
staff who requested lateral transfers, the number of times an employee 
requested a transfer, the number of requests approved or denied, or the 
reasons for denial. 

According to BOP, its central office exercises no role in reviewing 
decisions concerning lateral transfers where the warden is the deciding 
official. BOP officials stated that lateral transfers have not been 
considered a high-risk area necessitating review. At the regional 
level, officials from five of the six regions told us that their 
offices had no role concerning requests for lateral transfers where the 
warden was the deciding official. At the sixth region, an official said 
that starting in the first quarter of 2008 all wardens in that region 
were required to obtain authorization from the regional director before 
approving lateral transfers. According to this official, the approval 
policy was implemented because of a concern that transfers from hard- 
to-fill positions would contribute to turnover. At the facility level, 
if the warden at the employee's current facility decided not to forward 
the request or the warden at the desired facility denied the request, 
BOP had no formal process for reconsideration. 

Agencywide Policies, Procedures, and Monitoring Are Important for 
Ensuring Consistent Treatment of Staff: 

We have previously reported that it is important to have agencywide 
policies and procedures to help ensure consistent treatment, especially 
if employees are geographically dispersed across regions.[Footnote 9] 
Further, according to the Equal Employment Opportunity Commission's 
(EEOC) Management Directive 715, to ensure management and program 
accountability, agencies should maintain clearly defined, well- 
communicated personnel policies, and ensure that they are consistently 
applied.[Footnote 10] A Human Resources Specialist from the Office of 
Personnel Management's (OPM) Strategic Human Resource Policy Division 
told us that policies, procedures, and monitoring of employee-initiated 
reassignments are not required by regulation. However, according to the 
official, as with any other personnel action, documentation could be 
helpful if a personnel action is later questioned. The official also 
said that documentation of consistent treatment would also provide 
support for an agency's decision-making process when there are claims 
of favoritism and help an agency to avoid perceptions of inconsistent 
treatment. The absence of BOP-wide policies and procedures for lateral 
transfers diminishes BOP's ability to ensure consistent treatment of 
staff across BOP's 114 facilities in 6 regions. 

Our review of the policies and procedures of four other Justice law- 
enforcement components--the Federal Bureau of Investigation; the U.S. 
Marshals Service; the Bureau of Alcohol, Tobacco, Firearms, and 
Explosives; and the Drug Enforcement Administration--showed that each 
of these had established written policies and procedures applicable to 
some or all employees for requesting a transfer to another location. 
[Footnote 11] For example, the Marshals Service, whose policy is 
intended "to provide a standard, fair, and efficient means of 
considering employee requests for transfer," uses a centralized 
automated system where deputy U.S. Marshals can register their interest 
in transfers to district positions at General Schedule grades 12 and 
below in one or more geographic locations.[Footnote 12] For medical 
hardship requests, the policy also provides for a review panel whose 
decisions can be appealed to a designated agency official to approve or 
reject a request for a transfer. 

BOP Has Policies and Procedures for Staffing Temporary Assignments but 
Has Not Systematically Assessed Their Use: 

BOP has policies and procedures on how facilities are to assign staff 
on a temporary basis, but it has not systematically assessed how such 
temporary assignments are being made. As part of a cost-reduction 
strategy involving temporary assignments that began in 2004, in 2005 
BOP designated certain posts as "mission critical," that is, 
assignments that were deemed essential for the safe and secure 
operations of its facilities and would be vacated only in rare 
circumstances. The mission critical post initiative was intended to 
reduce facilities' reliance on overtime and non-correctional services 
staff, both of which had typically been used for temporary assignments. 
BOP provided facilities with general guidance on implementing the 
initiative but did not subsequently conduct an evaluation on the 
effectiveness of the initiative or determine whether it resulted in 
reduced reliance on overtime and use of non-correctional services staff 
for mission critical posts. Under the Standards for Internal Control in 
the Federal Government,[Footnote 13] federal agencies are to employ 
internal control activities, such as top-level review, to help ensure 
that management's directives are carried out and to determine if the 
agencies are effectively and efficiently using resources. BOP generally 
does not review data on temporary assignments at any level. In 
addition, BOP's computerized system cannot produce the summary data 
that would facilitate such a review. As a result, we had to conduct a 
manual review of temporary assignments. Our manual review showed that 
reliance on overtime and non-correctional services staff varied by 
facility and that some mission critical posts were left unassigned. 

BOP Policies and Procedures Provide Options for Temporarily Assigning 
Staff: 

BOP's written sources of policies and procedures on temporary 
assignments are the negotiated Master Agreement with AFGE and BOP's 
Correctional Services Procedures Manual. BOP's Master Agreement with 
AFGE provides that management, in accordance with applicable laws, has 
the right to assign work and to determine the personnel by which 
operations shall be conducted and outlines the negotiated procedures 
for assigning work and other matters subject to negotiation.[Footnote 
14] For example, according to the Agreement, employees shall be given 
at least 24-hours notice when it is necessary to make shift changes, 
except employees assigned to the sick and annual leave list or when the 
requirement for prior notice would cause vacating a post.[Footnote 15] 
Work assignments on the same shift may be changed without advance 
notice. In addition, when BOP determines that it is necessary to pay 
overtime for assignments normally filled by bargaining unit employees, 
the Agreement provides that qualified employees in the bargaining unit 
will receive first consideration for these overtime assignments and 
that these assignments will be distributed and rotated equitably among 
bargaining unit employees. Each facility may negotiate specific 
procedures regarding overtime assignment. The stated purpose of the 
Correctional Services Procedures Manual is to promote standard 
management practices for correctional services staff at all facilities, 
while recognizing the differences among facilities that vary in 
missions and security levels. The Manual requires facilities to use the 
computerized roster management system for the correctional services 
daily roster, reflecting all temporary assignments.[Footnote 16] 
According to interviews with BOP officials, all temporary assignments 
must be recorded in the computerized roster management system. 

As stated earlier, BOP uses temporary assignments, or day-to-day 
changes in correctional services assignments, for a variety of reasons 
including to fill in for staff regularly assigned to correctional 
services posts at BOP facilities who are absent because of illnesses or 
other reasons, such as training, or for special assignments. Special 
assignments are used to meet needs that arise in a facility and are not 
regularly assigned posts and may include escorted trips, airlifts, bus 
transports, and phone monitoring. Special assignments are used to 
address needs that could (1) arise unexpectedly, such as a medical 
emergency, or (2) be anticipated and may be planned for in advance, 
such as a scheduled educational activity or medical appointment. 

According to BOP officials, staffing decisions on temporary assignments 
are made at the discretion of each individual facility and are 
generally carried out by the lieutenants who are responsible for the 
day-to-day staffing of the correctional services departments. The 
options for staffing temporary assignments are not contained in BOP- 
wide written policy. However, according to officials at the facilities 
we interviewed, when there is a need for a temporary assignment, the 
assigning lieutenants have five options, as shown in figure 2. 

Figure 2: Options for Staffing a Temporary Assignment: 

[Refer to PDF for image] 

This figure is an illustration of a staffing plan for a temporary 
assignment, as follows: 

Facility lieutenant: Can choose from the following options to fill 
temporary assignments: 

Sick and annual list: 
Use staff assigned to the sick and annual list who serve as a 
designated group of officers used for a variety of reasons including to 
fill in for staff on leave, in training, or for special assignments. 
The number of staff on the sick and annual list varies by facility. 

Non-correctional services staff: 
Use staff regularly assigned to departments other than correctional 
services on a given day and shift, leaving the regular position of the 
non-correctional services staff vacant. 

Pay overtime/compensatory time: 
Use staff (correctional services or non-correctional services) not 
regularly assigned for the given day and shift that need to be filled. 
Overtime or compensatory time hours are in addition to the employee’s 
regularly assigned hours. 

Leave unassigned: 
Do not make a temporary assignment and leave the post or special 
assignment vacant. 

Correctional services staff assigned to other posts: 
Use correctional services staff regularly assigned to other posts. If 
this option is selected, this officer’s regular post would be vacant. 
The lieutenant would need to determine whether and how to fill the post 
or leave it unassigned. 

Source: GAO analysis based on BOP information. 

[End of figure] 

While most officials said that there were specific posts that should 
never be left unassigned--including the control room, towers, special 
housing unit, and mobile or perimeter patrol--officials from all of the 
facilities in our review said that some mission critical posts could go 
unassigned, depending on the type of post and the circumstances (e.g., 
in emergencies). For example, an official from one facility said that 
if there is snow on the ground and fewer inmates than normal are in the 
recreation yard, one or more recreation yard posts may go unassigned. 

BOP Implemented the Mission Critical Post Initiative to Achieve Cost 
Reductions for Temporary Assignments but Did Not Assess the 
Initiative's Effectiveness: 

In 2004, faced with significant budgetary constraints associated with 
increases in the inmate population, BOP began implementing a three- 
phase comprehensive strategy designed to streamline its operations and 
reduce costs. As part of its overall cost-reduction strategy, in 2005, 
BOP implemented the mission critical post initiative. The objectives of 
the mission critical post initiative were to (1) establish posts that 
were deemed essential for the safe and secure operations of its 
facilities and would be vacated only under rare circumstances, (2) 
reduce the reliance by the correctional services department on non- 
correctional services staff, and (3) substantially reduce overtime 
costs. According to BOP's Director, these objectives were to be 
achieved by making other correctional services posts available for 
relief and special assignments. Before the mission critical post 
initiative, special assignments had most often been covered by use of 
overtime or non-correctional services staff. 

Under the mission critical post initiative, BOP identified standard 
correctional services posts for each security level. These included 
posts that were mandated by current policy as well as posts that were 
determined to be essential for the daily operations of the facilities, 
such as those in the control room, where staff can monitor all facility 
activity and control entrances and exits, and housing units, which 
include sleeping spaces and a common area. BOP gave facility wardens 
final authority in designating mission critical posts to accommodate 
specific facility missions and designs, such as the needs of an older 
building, and to consider other factors. Correctional services posts 
deemed not mission critical, such as front gate or chapel officers, 
were eliminated. BOP guidance stated that certain essential duties, 
such as telephone monitoring, still needed to be accomplished despite 
the absence of a dedicated post. BOP guidance also required the 
facility captain to ensure that all other reasonable options had been 
exhausted before authorizing overtime to fill mission critical posts. 
However, BOP did not specify what such options were. Further, BOP's 
Correctional Services Procedures Manual, which provides guidance on 
assigning correctional services staff, was last updated in October 
2003, before the implementation of the mission critical post initiative 
and, therefore, does not provide further guidance on when it is 
appropriate to (1) use non-correctional services staff or (2) leave a 
mission critical post unassigned rather than pay overtime. 

A memorandum from the Assistant Director of Correctional Programs 
designated a 6-month evaluation period for the mission critical post 
initiative and described how BOP was to gather information from the 
facilities and how it was to evaluate the implementation of the 
initiative: 

"In order to monitor this process over the next 6 months, each Captain 
will be required to submit a weekly recapitulation to their (sic) 
respective Regional Correctional Services Administrator identifying 
their (sic) daily activity regarding local roster management. At 
minimum, the weekly recapitulation must consist of the amount of 
overtime used, number of posts filled by shift, the number of staff on 
day off, annual leave, sick leave, holiday, and training. The weekly 
recapitulation must be sent to the respective Regional Correctional 
Services Administrator by the close of business on Monday of the 
following week. At the end of the six-month period, the roster 
recapitulation results by institution will be analyzed regarding the 
amount of overtime used in regards to each institution's Custody 
staffing pattern and mission." 

According to BOP officials, BOP never conducted the analysis described 
in the memorandum and has not conducted any evaluation of the mission 
critical post initiative. BOP officials could not explain why the 
evaluation was not conducted. Such an evaluation would have been 
consistent with both the Standards for Internal Control in the Federal 
Government, which provide that federal agencies are to employ internal 
control activities, such as top-level review, to help ensure that 
management's directives are carried out and resources are effectively 
and efficiently used, and BOP's Management Control and Program Review 
Manual, which lays out the basic components of its system of management 
controls, which include assessing program performance regularly. 

BOP Management Generally Does Not Review Temporary Assignments: 

BOP's management generally does not review temporary assignments. For 
example, BOP's central office does not review temporary assignments, 
including the extent to which facilities leave mission critical posts 
unassigned or rely on overtime or non-correctional services staff to 
fill temporary assignments. Central office reviews, which are conducted 
by BOP's Program Review Division, generally every 3 years, are limited 
to reviewing a sample of daily rosters to ensure that the rosters are 
signed and properly maintained and do not include a review of temporary 
assignments. At the regional level, reviews of temporary assignments 
are generally limited to overtime usage and do not include reviews on 
the extent to which mission critical posts were left unassigned and the 
reliance on non-correctional services staff. While facilities in all 
six regions are to submit overtime reports to their regional offices 
for review, according to BOP written responses, these reports are not 
provided in a consistent manner throughout the agency and are used 
differently by each region. At the facility level, reviews of temporary 
assignments are mostly limited to the day-to-day reviews of the daily 
rosters generally to verify accuracy.[Footnote 17] In addition, 
officials from one of the seven facilities reported tracking mission 
critical posts left unassigned on daily rosters, and the warden at that 
facility said that he randomly reviews daily rosters on a weekly basis. 
Without reviewing unassigned mission critical posts, facilities cannot 
determine whether leaving mission critical posts unassigned has an 
effect on facilities' safety and security. 

Because of limitations with BOP's computerized roster management 
system, the only way currently for BOP to assess how it is temporarily 
assigning staff would be for BOP officials to manually review daily 
rosters. The system does not produce summary data on temporary 
assignments and does not produce reliable historical data on non- 
correctional services positions. While the system contains data on 
temporary assignments for individual days, it currently does not 
produce summary data that would make it easier for BOP officials to 
assess BOP's use of temporary assignments. For example, when a facility 
leaves a mission critical post unassigned, it is designated on the 
correctional services daily roster, but BOP's computerized system does 
not produce summary data on the number of mission critical posts left 
unassigned. To obtain summary data, a facility would have to count the 
occurrences of unassigned posts from each daily roster for a given 
period. In addition, although the system can produce limited data on 
overtime and non-correctional services staff by individual days, 
[Footnote 18] it does not produce summary data over time on the use of 
overtime or non-correctional services staff or the purposes for which 
overtime was paid or non-correctional services staff were used. In 
March 2008, one region began manually reviewing individual daily 
rosters submitted by its facilities.[Footnote 19] Officials in that 
region said that two staff members currently spend about an hour a day 
reviewing the rosters and that one staff member is spending about an 
hour and a half reviewing the rosters on a weekly basis. Also according 
to BOP officials responsible for the design and implementation of the 
system, although it distinguishes between correctional services and non-
correctional services staff, if an employee moves from a correctional 
services position to a non-correctional services position or vice 
versa, the employee's department status would change for all rosters 
that are stored on the system before the move. As a result, any 
historical data on the use of non-correctional services staff is not 
reliable, and only hard copy versions of daily rosters maintained at a 
facility are an accurate record. Without summary data on the use of 
overtime and non-correctional services staff and the purposes for which 
overtime was paid or non-correctional services staff were used, BOP 
cannot assess whether the policy changes it made involving temporary 
assignments enabled BOP to achieve its goals of reducing its reliance 
on overtime and non-correctional services staff. Also without summary 
data on unassigned mission critical posts, BOP cannot assess the 
effect, if any, of such posts on the safety and security of its 
facilities. Further, without reliable data on the use of non- 
correctional services positions, BOP cannot accurately assess the 
extent to which it has reduced its reliance on non-correctional 
services staff. 

Manual Review of Temporary Assignments Shows That BOP Facilities Left 
Mission Critical Posts Unassigned and Relied on Overtime and Non- 
Correctional Services Staff to Varying Degrees: 

Our review of BOP's management of temporary assignments included 
determining how BOP temporarily assigned staff, specifically the extent 
to which the facilities in our review left mission critical posts 
unassigned and relied on overtime and non-correctional services staff 
for temporary assignments. Because of the limitations with BOP's 
computerized roster management system, we manually reviewed individual 
daily rosters. For each of the facilities in our review, we analyzed a 
stratified random sample of 60 correctional services daily rosters, 5 
per month, for calendar year 2007. We counted for both mission critical 
posts and special assignments the occurrences of (1) unassigned posts, 
(2) non-correctional services staff paid regular time, (3) correctional 
services staff paid overtime, (4) non-correctional services staff paid 
overtime, and (5) compensatory time and statistically estimated the 
average number and percentage of mission critical posts and special 
assignments for each of these categories.[Footnote 20] We also counted 
the total number of special assignments. We did not review daily 
rosters completed before the implementation of the mission critical 
post initiative and therefore do not know the impact of the initiative. 
Appendix I provides detailed information on the methods we used for 
conducting our analysis. Appendix III provides the results of our 
analysis for each of the facilities in our review. 

Our analysis showed that facilities in our review left mission critical 
posts unassigned, with an estimated low of 3 percent of mission 
critical posts per day on average at two facilities and an estimated 
high of 12 percent per day on average at another facility. Facilities 
differed in the occurrences of overtime to fill mission critical posts, 
with estimated low of 1 percent per day on average and a estimated high 
of 6 percent per day on average and for special assignments an 
estimated low of 21 percent of special assignments per day on average 
and an estimated high of 63 percent per day on average. Facilities 
differed in the of use of non-correctional services staff to fill 
mission critical posts, with an estimated low of 1 percent of mission 
critical posts per day on average and an estimated high of 10 percent 
per day on average and for special assignments an estimated low of 2 
percent of special assignments per day on average and an estimated high 
of 25 percent per day on average. It is unclear the extent to which 
leaving mission critical posts unassigned, paying overtime, and using 
non-correctional services staff may affect the safety and security of 
BOP's operations. 

Conclusions: 

BOP does not have written policies and procedures for managing lateral 
transfers. Without such policies and procedures, BOP cannot ensure that 
staff at each of its 114 facilities in 6 regions across the United 
States have similar processes available to them or are being 
consistently treated when they request lateral transfers. While BOP 
does have processes in place for managing temporary assignments, it has 
not evaluated the effectiveness of its mission critical post initiative 
nor systematically assessed temporary assignments. Without such 
assessments, BOP is not employing internal control activities specified 
in federal standards and BOP policy and, therefore, cannot determine 
whether it is achieving the desired cost savings or determine the 
effect, if any, of unassigned mission critical posts on the safety and 
security of its facilities. 

Recommendations for Executive Action: 

We recommend that the Attorney General direct the Director of BOP to: 

* develop and implement specific policies and procedures for 
administering employee requests for lateral transfers, including the 
collection of data on such requests and their outcomes and the 
development of a system of oversight to ensure the consistent treatment 
of BOP staff and: 

* systematically assess temporary assignments to ensure that BOP is 
meeting the objectives of the mission critical post initiative and 
effectively and efficiently using resources. 

Agency Comments and Our Evaluation: 

In a letter dated February 5, 2009 (see appendix IV), the Director of 
BOP, on behalf of the Attorney General, agreed with our findings. 
Regarding our first recommendation, the Director disagreed with the 
recommended action that BOP develop and implement specific policies and 
procedures for administering employee requests for lateral transfers 
because BOP would have to devote time and personnel to developing 
policies and procedures and maintaining such a program. In addition, 
the Director stated that implementation of our recommendation would 
elevate this process to a central office function rather than retain it 
at the local level where staffing decisions are made. While developing, 
implementing, and overseeing policies and procedures that we recommend 
would require some resources, these actions would not necessarily 
require centralizing either decisions on requests for lateral transfers 
or the data collection on such requests and their outcomes. For 
example, decisions on transfer requests could primarily remain at the 
facility level; facilities would collect and retain data on all 
requests and their disposition and facilities would then report these 
data on lateral transfers to BOP. This would allow BOP to conduct 
appropriate oversight to ensure that requests for lateral transfers are 
handled consistently across facilities. The Director stated that 
instead of implementing our recommendation, BOP plans to "encourage a 
practice to have locations post a vacancy announcement on USAJobs 
before filling local vacancies." Such a plan would fall short of the 
intent of our recommendation of having specific policies and procedures 
for facilities across BOP to administer employee requests for lateral 
transfers, including the collection of data on such requests and their 
outcomes and the development of a system of oversight to ensure 
consistent treatment of staff. We continue to believe that without such 
written policies and procedures covering lateral transfers, BOP cannot 
readily monitor how such transfers are being managed across BOP or 
ensure that staff are being consistently treated when requesting such 
transfers. 

Regarding our second recommendation, the Director stated that BOP will 
conduct a systematic assessment of the use of correctional services 
mission critical posts at its field locations from January 1 through 
December 31, 2009. Further, the assessment will include the issue of 
vacating posts. After the initial assessment, BOP's Correctional 
Services Program Review Guidelines will be modified as appropriate 
based on BOP's findings, and BOP plans to conduct regularly scheduled 
reviews of institutions to determine whether it is meeting its mission 
critical post initiative and effectively and efficiently using 
resources. 

We will send copies of this report to the Attorney General and other 
interested parties. Copies will be made available to others upon 
request. This report will also be available at no charge on GAO's Web 
site at [hyperlink, http://www.gao.gov]. 

If you have questions about this report, please contact me on (202) 512-
9490 or at stalcupg@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Staff who made major contributions are listed in 
appendix V. 

Signed by: 

George H. Stalcup: 
Director, Strategic Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to identify whether BOP had policies and procedures 
and how it assessed the management of those policies and procedures for 
(1) permanent reassignments of BOP employees between correctional 
facilities and (2) temporary assignments of BOP employees within a 
correctional facility. For purposes of this report, permanent 
reassignments, referred to as lateral transfers by BOP, are employee- 
requested transfers to other BOP facilities that do not involve a 
promotion or demotion. Temporary assignments are day-to-day changes in 
correctional services assignments at BOP facilities made for a variety 
of reasons including (1) to fill in for staff regularly assigned to 
correctional services posts who are absent because of illnesses or 
other reasons, such as training, or (2) for special assignments (i.e., 
to meet needs that arise in a facility and are not regularly assigned 
posts).[Footnote 21] 

As part of our review, we selected seven facilities, which included 
five separately located facilities and two federal correctional 
complexes (FCC).[Footnote 22] We selected facilities based on the 
number of staff, as reported in BOP's 2006 State of the Bureau, with at 
least one facility from within each of BOP's six regions, and included 
low-and medium-security federal correctional institutions (FCI) and 
high-security United States Penitentiaries (USP). Because of their 
specialized missions, we excluded administrative facilities, such as 
Federal Detention Centers, Federal Medical Centers, and the 
Administrative-Maximum USP. To select the FCCs, we included an 
additional criterion, whether the FCC used separate rosters to assign 
staff at each of the facilities in the complex or one consolidated 
roster to assign staff throughout the complex. Based on information 
provided by BOP, we selected the FCC with the highest number of staff 
that uses a consolidated roster, FCC Terre Haute (consisting of two 
facilities, a high-security and a medium-security) in the North Central 
Region, and the FCC with the highest number of staff that uses separate 
rosters, FCC Coleman (consisting of four facilities--two high-security, 
one medium-security, and one low-security) in the Southeast Region. For 
the remaining regions, we selected the facility in each region with the 
highest number of staff. In the Mid-Atlantic region, we selected the 
two facilities with the highest number of staff, one at which to 
conduct a site visit. We selected low-security FCI Fort Dix in the 
Northeast Region, medium-security FCI Sheridan in the Western Region, 
and the following high-security USPs: Hazelton and Lee in the Mid- 
Atlantic Region and Pollock in the South Central Region. We conducted a 
site visit to USP Hazelton and interviewed officials at the other 
facilities by video conference. 

Objective 1: Lateral Transfers of BOP Employees among Correctional 
Facilities: 

To identify whether BOP had policies and procedures on lateral 
transfers and how it assessed the management of such policies, we 
requested documentation on such policies and procedures. We also 
interviewed officials from BOP's Human Resources and Program Review 
divisions, each of its regional offices, its Consolidated Employee 
Service Center in Grand Prairie, Tex., and the seven facilities in our 
review. We interviewed representatives of the American Federation of 
Government Employees Council of Prison Locals (AFGE) and reviewed 
AFGE's Master Agreement with BOP. To obtain information about the use 
of written policies, procedures, and oversight of lateral transfers in 
the federal government, we interviewed an official from the Office of 
Personnel Management's Strategic Human Resources Policy Division. We 
also requested and reviewed documentation on the extent to which four 
other Department of Justice law enforcement components--Bureau of 
Alcohol, Tobacco, Firearms and Explosives; Drug Enforcement 
Administration; Federal Bureau of Investigation; and United States 
Marshals Service--had written policies and procedures in place for such 
reassignments. 

To identify the number of BOP employees who were permanently reassigned 
for fiscal years 2004 through 2007, we requested and obtained National 
Finance Center (NFC) data from BOP on the number of permanent 
reassignments.[Footnote 23] These data included those successfully 
reassigned through all types of permanent reassignments, including 
lateral transfers, agency-initiated reassignments, application for an 
announced vacancy, BOP's Management Selection System, and the Open 
Continuous Announcement System, but BOP could not separate the data by 
type of reassignment. We compared the NFC data with data on permanent 
reassignments generated by the Office of Personnel Management's Central 
Personnel Data File. The discrepancies were small enough for us to 
determine that the NFC data were sufficiently reliable for the purposes 
of this report. 

Objective 2: Temporary Assignments of BOP Employees within Correctional 
Facilities: 

To identify whether BOP had policies and procedures and how it assessed 
the management of its policies and procedures for temporary assignments 
of BOP employees within correctional facilities, we reviewed BOP 
program statements and other guidance related to temporary assignments. 
We interviewed the relevant officials at BOP's central and regional 
offices, and at each of the selected facilities. We also interviewed 
representatives of AFGE and reviewed AFGE's Master Agreement with BOP. 

To determine how the facilities in our review used temporary 
assignments, we analyzed correctional services daily rosters provided 
by BOP for each of the facilities included in our review. BOP 
facilities maintain daily rosters in two ways: (1) in its computerized 
roster management system, which can be accessed at a later date and (2) 
as hard copies stored at each facility. We analyzed hard-copy 
correctional services daily rosters from facilities in our review 
because BOP's computerized roster management system does not produce 
historically accurate data on the department status of correctional 
services and non-correctional services staff that are sufficiently 
reliable for purposes of this report. According to BOP officials 
responsible for the design and implementation of BOP's computerized 
system, although the system distinguishes between correctional services 
and non-correctional services staff, if an employee moves from a 
correctional services position to a non-correctional services position 
or vice versa, the employee's department status would change for all 
rosters that are stored in the system before the move. 

To determine the reliability of the hard-copy daily rosters, we 
reviewed training and other technical documentation associated with the 
computerized roster management system used at BOP facilities and BOP's 
policies and procedures for ensuring the accuracy of the data. We 
interviewed BOP's Correctional Services Administrator; BOP officials 
responsible for designing, maintaining, and updating the computerized 
roster management system and for organizing system training at the 
facilities; and BOP officials from each of the seven facilities in our 
review knowledgeable about entering data and generating daily rosters. 
We determined that the data contained in the official hard-copy 
correctional services daily rosters were sufficiently reliable for the 
purposes of this report. BOP considers the hard-copy daily rosters the 
official record of staffing in correctional services, including the use 
of overtime and the use of non-correctional services staff. According 
to facility officials we interviewed, the evening watch lieutenant and 
captain review and sign each day's hard-copy roster for accuracy, 
typically within the 24 to 48 hours following the end of the last shift 
of the day. That roster then becomes the final version. BOP requires 
the signed hard-copy daily rosters to be stored at the facility for 10 
years.[Footnote 24] 

We did not evaluate the accuracy of information on the individual daily 
rosters. We excluded those hard-copy daily rosters that were printed 
more than 30 days after the date of the daily roster because we 
determined that the designations on non-correctional services staff 
were not sufficiently reliable for the purposes of this report. 
[Footnote 25] We also excluded from our analysis incomplete daily 
rosters (i.e., those that were sent to us with missing pages) and 
rosters that we did not receive.[Footnote 26] 

Analysis of Daily Rosters: 

To analyze the correctional services daily rosters from each of the 
facilities in our review, we selected a stratified random sample of 60 
hard-copy daily rosters, 5 per month, from the universe of 365 daily 
rosters per facility for calendar year 2007. We did not look at daily 
rosters completed before the implementation of the mission critical 
initiative and therefore do not know the impact of the initiative. For 
FCC Coleman, which uses separate daily rosters to assign staff at each 
of its four facilities, we reviewed the separate rosters from each 
facility for the 60 days. For FCC Terre Haute, which uses a 
consolidated roster to assign staff throughout the complex, we reviewed 
the consolidated daily roster for the 60 days. In total, we reviewed 
600 daily rosters. With this stratified random sample, each roster in 
the universe had a chance of being selected. Each selected roster was 
subsequently weighted in the analysis to account statistically for all 
the members of the universe, including those who were not selected. 

For each day selected in the sample, on the daily roster we manually 
counted for both mission critical posts and special assignments 
occurrences of (1) unassigned posts, (2) non-correctional services 
staff paid regular time, (3) correctional services staff paid overtime, 
(4) non-correctional services staff paid overtime, and (5) compensatory 
time. In addition, we counted the total number of special assignments 
assigned per day at each facility in our review. Based on these 
results, we estimated the average daily number and percentage of 
mission critical posts and special assignments that were unassigned, 
filled with non-correctional services staff, or filled with overtime 
using either correctional services staff or non-correctional services 
staff. These results are limited to the facilities in our review for 
calendar year 2007 and are not intended to be applied to facilities 
across BOP. 

For the overtime results, we based the average daily count on the 
number of overtime occurrences rather than number of overtime hours. 
The total number of overtime occurrences per day was determined by 
adding the daily count of occurrences of correctional services staff 
paid overtime and non-correctional services staff paid overtime. 

Because of resource constraints, we did not count the total number of 
mission critical posts listed on each of the 600 daily rosters. This 
would have provided the actual total number of mission critical posts 
for each day. Instead, we calculated daily percentages based on the 
maximum number of posts possible per day in the facility, which ranged 
from 70 mission critical posts at low-security FCI Coleman to 232 
mission critical posts at FCC Terre Haute.[Footnote 27] BOP facilities 
determine the number of days needed for each post, and posts are 
designated as consisting of between 1 to 7 day shifts per week. For 
example, a visiting-room post was identified as a 2-day shift per week 
at one facility in our review. We assumed for each day in our sample 
that each mission critical post would be listed on the daily roster-- 
that is, the visiting room would be staffed on each day of our sample. 
Because it is likely that not every post would be included on the daily 
roster on each of the days in our sample and that the actual number of 
posts listed on the roster would be less than the maximum number of 
posts possible in a day at that facility, our methodology potentially 
underestimates the results. 

Because we followed a procedure based on random selection, each of our 
samples is only one of a large number of samples that we might have 
drawn. Since each possible sample could have provided different 
estimates, we express our confidence in the precision of our particular 
sample's results as a 95 percent confidence interval. This is the 
interval that would contain the actual value for 95 percent of the 
samples we could have drawn from the universe. For mission critical 
posts, each estimate from these samples has a margin of error at the 95 
percent confidence level, of plus or minus 2 percent or less for 
average daily percentage estimates or plus or minus 4 posts or less for 
average daily post estimates. For special assignments, each estimate 
from these samples has a margin of error, at the 95 percent confidence 
level, of plus or minus 6 percent or less for average daily percentage 
estimates or plus or minus 3 special assignments or less for average 
daily special assignments estimates. 

We conducted this performance audit from August 2007 to January 2009 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: BOP's Correctional Services Roster Assignment and 
Temporary Assignment Process: 

This appendix describes how BOP assigns staff to correctional services 
mission critical posts and makes temporary assignments to these posts 
and special assignments. 

Assignments to Mission Critical Posts: 

BOP correctional services staff are assigned to or selected for two 
types of mission critical posts, rotating and non-rotating. Most posts 
in a facility are rotating posts and are assigned on a quarterly basis 
in accordance with the bidding procedures contained in the Master 
Agreement between BOP and AFGE. The outcome of the bid process 
represents the correctional services assignments for that specific 
quarter. These include such posts as the control room, where staff can 
monitor all facility activity and control entrances and exits, and 
housing units, which include inmate sleeping spaces and a common area. 
Staff may also bid on what are called "sick and annual" posts. Staff 
who hold sick and annual posts serve as a designated group of officers 
used for a variety of reasons, including filling in for staff on leave, 
in training, or for special assignments. Non-rotating posts are not 
open to quarterly bidding, and staff are assigned or selected on a 
permanent basis. These include such posts as captain's secretary, 
captain, and special investigative agent. Assignments to mission 
critical post (rotating and non-rotating) are reflected on each 
facility's quarterly roster that is prepared and stored in each 
facility's computerized roster management system.[Footnote 28] The 
quarterly roster reflects all staff assigned to posts for the quarter 
and serves as the basis for all daily rosters for that quarter and is 
generated from each facility's computerized system. 

Temporary Assignments to Mission Critical Posts and Special 
Assignments: 

Approximately 2 weeks before a particular date, the designated 
administrative lieutenant at each facility generates the daily roster 
from the computerized system. Subsequently, designated supervisory 
staff, typically other lieutenants, enter temporary assignments 
directly into the computerized system to reflect correctional services 
staff requests for leave and special assignments. In staffing temporary 
assignments, lieutenants are to consider the number of staff needed and 
the specialized experience, training, or certification required for 
some posts and special assignments and the qualifications of available 
staff. For example, in cases of medical escort special assignments, BOP 
policy requires a 3-to-1 staff-to-inmate ratio for maximum custody 
inmates, but only a 2-to-1 ratio for high-and medium-custody inmates. 
To escort an inmate to an outside medical facility, the staff assigned 
must have completed basic prisoner transport training and be 
recertified annually. Names of staff who are current on this 
certification and certifications required for other posts or special 
assignments are contained on lists available to the assigning 
lieutenant and are available under the staff member's name in the 
computerized system. In addition, officials from some facilities and 
regional offices told us that staff assigned to some posts, while not 
requiring a formal certification, should have a certain level of 
knowledge or experience. For example, in the control room, officials 
told us that it is important to have someone with knowledge of the 
facility to fill in for someone regularly assigned. Finally, officials 
from two facilities said that certain non-rotating posts--those that 
are not assigned on a quarterly basis--such as special investigative 
agent, emergency planning officers, captain's secretary, captain, and 
deputy captain could go temporarily unassigned, and officials from one 
of these facilities said staff assigned to some non-rotating posts are 
used for temporary assignments to mission critical posts and special 
assignments. Temporary assignments are made as necessary until the end 
of the last shift of the day (i.e., midnight). 

[End of section] 

Appendix III: Analysis of Correctional Services Daily Rosters at 
Selected BOP Facilities: 

This appendix describes the results of our analysis of correctional 
services daily rosters of how each of the facilities in our review used 
temporary assignments to mission critical posts and special assignments 
for calendar year 2007. For a more detailed description of the methods 
we used to conduct our analysis, see appendix I. 

Mission Critical Posts: 

Our analysis showed that during calendar year 2007 facilities in our 
review left mission critical posts unassigned ranging from an estimated 
low of 3 percent per day on average at FCI Sheridan and FCI Coleman 
Medium to an estimated high of 12 percent per day on average at USP 
Coleman II. Figure 3 shows the 2007 estimated average daily percentage 
of unassigned mission critical posts for each of the facilities we 
reviewed. We did not analyze which specific posts went unassigned 
(e.g., rotating or non-rotating posts or posts by name). 

Figure 3: Estimated Average Daily Percentage of Unassigned Mission 
Critical Posts at Selected BOP Facilities, 2007: 

[Refer to PDF for image] 

This figure is vertical bar graph depicting the following data: 

BOP Facility: FCI Ft. Dix; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 7%. 

BOP Facility: FCI Sheridan; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 3%. 

BOP Facility: USP Hazelton; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 6%. 

BOP Facility: USP Lee; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 4%. 

BOP Facility: USP Pollock; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 4%. 

BOP Facility: FCI Coleman low; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 4%. 

BOP Facility: FCI Coleman medium; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 3%. 

BOP Facility: USP Coleman I; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 6%. 

BOP Facility: USP Coleman II; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 12%. 

BOP Facility: FCC Terre Haute; 
Estimated Average Daily Percentage of Unassigned Mission Critical 
Posts: 4%. 

Source: GAO analysis of BOP correctional services daily rosters. 

Note: All estimates have a margin of error, at the 95 percent 
confidence level, of plus or minus 2 percent or less for average daily 
percentage estimates. 

[End of figure] 

Facilities paid overtime to fill, on average, an estimated low of 1 
percent per day of mission critical posts at USP Lee and a high of 6 
percent per day of mission critical posts at FCI Coleman Low, FCI 
Coleman Medium, and USP Coleman II, as figure 4 shows. 

Figure 4: Estimated Average Daily Percentage of Mission Critical Posts 
Filled with Overtime at Selected BOP Facilities, 2007: 

[Refer to PDF for image] 

This figure is vertical bar graph depicting the following data: 

BOP Facility: FCI Ft. Dix; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 4%. 

BOP Facility: FCI Sheridan; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 2%. 

BOP Facility: USP Hazelton; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 5%. 

BOP Facility: USP Lee; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 1%. 

BOP Facility: USP Pollock; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 2%. 

BOP Facility: FCI Coleman low; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 6%. 

BOP Facility: FCI Coleman medium; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 6%. 

BOP Facility: USP Coleman I; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 5%. 

BOP Facility: USP Coleman II; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 6%. 

BOP Facility: FCC Terre Haute; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Overtime: 2%. 

Source: GAO analysis of BOP correctional services daily rosters. 

Notes: Averages are based on the number of overtime occurrences rather 
than number of overtime hours. The total number of overtime occurrences 
per day was determined by summing the daily count of occurrences of 
correctional staff paid overtime and non-correctional services staff 
paid overtime. 

All estimates have a margin of error, at the 95 percent confidence 
level, of plus or minus 2 percent or less for average daily percentage 
estimates. 

[End of figure] 

Facilities used non-correctional services staff to fill, on average, an 
estimated low of 1 percent per day of mission critical posts at FCI 
Sheridan, USP Hazelton, USP Lee, USP Pollock, and FCC Terre Haute and a 
high of 10 percent per day of mission critical posts at FCI Coleman 
Medium, as figure 5 shows. 

Figure 5: Estimated Average Daily Percentage of Mission Critical Posts 
Filled with Non-Correctional Services Staff at Selected BOP Facilities, 
2007: 

[Refer to PDF for image] 

This figure is vertical bar graph depicting the following data: 

BOP Facility: FCI Ft. Dix; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 4%. 

BOP Facility: FCI Sheridan; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 1%. 

BOP Facility: USP Hazelton; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 1%. 

BOP Facility: USP Lee; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 1%. 

BOP Facility: USP Pollock; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 1%. 

BOP Facility: FCI Coleman low; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 8%. 

BOP Facility: FCI Coleman medium; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 10%. 

BOP Facility: USP Coleman I; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 7%. 

BOP Facility: USP Coleman II; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 7%. 

BOP Facility: FCC Terre Haute; 
Estimated Average Daily Percentage of Mission Critical Posts Filled 
with Non-Correctional Services Staff: 1%. 

Source: GAO analysis of BOP correctional services daily rosters. 

Notes: Averages are based on the number of occurrences of non- 
correctional services staff used rather than number of hours worked. 
The total number of non-correctional services staff occurrences per day 
was determined by summing the daily count of occurrences of non- 
correctional services staff paid regular time and non-correctional 
services staff paid overtime. 

All estimates have a margin of error, at the 95 percent confidence 
level, of plus or minus 2 percent or less for average daily percentage 
estimates. 

[End of figure] 

An official from one facility said he tries not to use non-correctional 
services staff for temporary assignments because they have their own 
assignments to complete and being reassigned to a post would disrupt 
that work. Officials from six of the facilities told us that they 
regularly use non-correctional services staff for temporary assignments 
during annual refresher training, a 1-week course that occurs several 
times a year at each facility and is required for all facility staff. 

Special Assignments: 

The estimated average number of special assignments per day ranged from 
10 at FCI Coleman low and medium to 47 at FCC Terre Haute (one high- 
security and one low-security), as table 1 shows. 

Table 1: Estimated Average Daily Number of Special Assignments and 
Number Unassigned for Selected BOP Facilities, 2007: 

Institution: FCI Ft. Dix; 
Average number of special assignments: 16; 
Average number of unassigned special assignments: 0. 

Institution: FCI Sheridan; 
Average number of special assignments: 16; 
Average number of unassigned special assignments: 1. 

Institution: USP Hazelton; 
Average number of special assignments: 25; 
Average number of unassigned special assignments: 1. 

Institution: USP Lee; 
Average number of special assignments: 22; 
Average number of unassigned special assignments: 8. 

Institution: USP Pollock; 
Average number of special assignments: 16; 
Average number of unassigned special assignments: 1. 

Institution: FCI Coleman Low; 
Average number of special assignments: 10; 
Average number of unassigned special assignments: 0. 

Institution: FCI Coleman Medium; 
Average number of special assignments: 10; 
Average number of unassigned special assignments: 0. 

Institution: USP Coleman I; 
Average number of special assignments: 18; 
Average number of unassigned special assignments: 1. 

Institution: USP Coleman II; 
Average number of special assignments: 20; 
Average number of unassigned special assignments: 0. 

Institution: FCC Terre Haute; 
Average number of special assignments: 47; 
Average number of unassigned special assignments: 1. 

Source: GAO analysis of BOP correctional services daily rosters. 

Note: All estimates have a margin of error of plus or minus 3 
assignments or less for the average number of special assignments 
estimates and plus or minus 6 percent or less for the average 
percentage estimates or less at the 95 percent confidence level. 

[End of table] 

On average, the facilities in our review filled nearly all special 
assignments, with the exception of USP Lee, which left an estimated 8 
of 22, or 37 percent, of special assignments unassigned per day. 

The facilities in our review paid overtime to fill, on average, an 
estimated low of 21 percent of special assignments per day at USP Lee 
and a high of 63 percent at FCC Terre Haute, as figure 6 below shows. 

Figure 6: Estimated Average Daily Percentage of Special Assignments 
Filled with Overtime at Selected BOP Facilities, 2007: 

[Refer to PDF for image] 

This figure is vertical bar graph depicting the following data: 

BOP Facility: FCI Ft. Dix; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 31%. 

BOP Facility: FCI Sheridan; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 38%. 

BOP Facility: USP Hazelton; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 48%. 

BOP Facility: USP Lee; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 21%. 

BOP Facility: USP Pollock; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 29%. 

BOP Facility: FCI Coleman low; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 37%. 

BOP Facility: FCI Coleman medium; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 37%. 

BOP Facility: USP Coleman I; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 40%. 

BOP Facility: USP Coleman II; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 44%. 

BOP Facility: FCC Terre Haute; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Overtime: 63%. 

Source: GAO analysis of BOP correctional services daily rosters. 

Notes: Averages are based on the number of overtime occurrences rather 
than number of overtime hours worked. The total number of special 
assignment overtime occurrences per day was determined by summing the 
daily count of occurrences of correctional services staff paid overtime 
and non-correctional services staff paid overtime. 

All estimates have a margin of error of plus or minus 6 percent or less 
for the average percentage estimates or less at the 95 percent 
confidence level. 

[End of figure] 

The facilities in our review used non-correctional services staff to 
fill, on average, an estimated low of 2 percent of special assignments 
per day at FCI Sheridan and FCC Terre Haute and a high of 25 percent 
per day at FCI Ft. Dix, as figure 7 shows. 

Figure 7: Estimated Average Daily Percentage of Special Assignments 
Filled with Non-Correctional Services Staff at Selected BOP Facilities, 
2007: 

[Refer to PDF for image] 

This figure is vertical bar graph depicting the following data: 

BOP Facility: FCI Ft. Dix; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 25%. 

BOP Facility: FCI Sheridan; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 2%. 

BOP Facility: USP Hazelton; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 6%. 

BOP Facility: USP Lee; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 3%. 

BOP Facility: USP Pollock; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 6%. 

BOP Facility: FCI Coleman low; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 18%. 

BOP Facility: FCI Coleman medium; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 20%. 

BOP Facility: USP Coleman I; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 12%. 

BOP Facility: USP Coleman II; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 10%. 

BOP Facility: FCC Terre Haute; 
Estimated Average Daily Percentage of Special Assignments Filled with 
Non-Correctional Services Staff: 2%. 

Source: GAO analysis of BOP correctional services daily rosters. 

Notes: Percentages are based on the number of occurrences of non- 
correctional services staff used rather than number of hours worked. 
The total number of non-correctional services staff used per day was 
determined by summing the daily count of occurrences of non- 
correctional services paid regular time overtime and non-correctional 
services staff paid overtime. 

All estimates have a margin of error of plus or minus 6 percent or less 
for the average percentage estimates or less at the 95 percent 
confidence level. 

[End of figure] 

[End of section] 

Appendix IV: Comments from the U.S. Department of Justice: 

U.S. Department of Justice: 
Federal Bureau of Prisons: 
Office of the Director: 
Washington, DC 20534: 

February 5, 2009: 

George H. Stalcup, Director: 
Strategic Issues: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Stalcup: 

The Bureau of Prisons (BOP) appreciates the opportunity to formally 
respond to the Government Accountability Office's draft report entitled 
Bureau of Prisons: Written Policies on Lateral Transfers and Assessment 
of Temporary Assignments Needed. We have completed our review of the 
information reflected in the report and offer the following comments. 

Recommendation 1: To the Attorney General to direct the Director of BOP 
to develop and implement specific policies and procedures for 
administering employee requests for lateral transfers, including the 
collection of data on such requests and their outcomes and the 
development of a system of oversight to ensure the consistent treatment 
of BOP staff. 

Response: While the Bureau agrees with the accuracy of the findings 
which indicate there are no written policies on this issue, we 
respectfully disagree with the recommended action to be taken by our 
agency. 

The recommendation was made to develop and implement specific policies 
and procedures for administering employee requests for lateral 
transfers, including the collection of data on such requests and their 
outcomes and the development of a system of oversight to ensure the 
consistent treatment of Bureau staff. By doing so, the Bureau would 
need to devote time and personnel to developing the policies and 
procedures, as well as commit resources to maintain such a program. 
Additionally, this would elevate the process to a Central Office 
function, rather than retain it at the local level with the CEO of the 
location, where the staffing decisions are made. As noted in the 
report, our current practice does not violate any staffing regulations. 
Therefore, we do not feel it is necessary or a good use of resources to 
initiate a national program to minimize possible risk of complaints of 
favoritism. However, to address GAO's concerns, the Bureau will 
encourage a practice to have locations post a vacancy announcement on 
USAJOBS before filling local vacancies. This will afford interested, 
qualified individuals an opportunity to apply. This modification to our 
current practice meets the needs of our staff while ensuring oversight 
and consistent treatment, consequently, the Bureau requests this 
recommendation be closed. 

Recommendation 2: To the Attorney General to direct the Director of BOP 
to systematically assess temporary assignments to ensure that BOP is 
meeting the objectives of the mission critical post initiative and 
effectively and efficiently using resources. 

Response: The Bureau will conduct a systematic assessment of 
Correctional Services "mission critical post" use at its field 
locations. Utilization of resources (staffing, overtime, etc.) and the 
issue of vacating posts will be examined. This assessment will commence 
immediately and cover the one-year period from January 1 through 
December 31, 2009. After this initial assessment, Correctional Services 
Program Review Guidelines will be modified as appropriate based on the 
findings. Subsequent, regularly-scheduled reviews of institutions will 
continuously address whether the Bureau is meeting its mission critical 
post initiative and effectively and efficiently using resources. The 
initial assessment and subsequent program reviews will address GAO's 
recommendation, so the Bureau requests this recommendation be closed. 

If you have any questions regarding this response, please contact 
VaNessa P. Adams, Senior Deputy Assistant Director, Program Review 
Division, at (202) 616-2099. 

Sincerely, 

Signed by: 

Harley G. Lappin: 
Director: 

cc: Richard Theis, Assistant Director: 
Audit Liaison Group, JMD: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George H. Stalcup on (202) 512-9490 or at stalcupg@gao.gov: 

Acknowledgments: 

In addition to the individual named above, Kiki Theodoropoulos, 
Assistant Director; James Ashley; Dewi Djunaidy; Karin Fangman; Tamara 
F. Stenzel; and Gregory H. Wilmoth made key contributions to this 
report. 

[End of section] 

Footnotes: 

[1] The remaining approximately 36,000 inmates are confined through 
agreements with state and local governments or through contracts with 
privately-operated residential re-entry centers, detention centers, 
prisons, and juvenile facilities. 

[2] BOP stated in a written response that employees may also be 
permanently reassigned through (1) agency-initiated reassignments, 
generally of management staff; (2) application for an announced 
vacancy; (3) the Management Selection System for wardens and associate 
wardens; and (4) the Open Continuous Announcement System for 
supervisory correctional officers. We did not review BOP's policies and 
procedures and BOP's assessment of the management of its policies and 
procedures on these other types of permanent reassignments. 

[3] A post is the location or assignment that is worked by staff. 
Temporary assignments are reflected on BOP facilities' correctional 
services daily rosters, which identify all individuals assigned to 
correctional services for the day and are generated using BOP's 
correctional services computerized roster management system. BOP 
considers the correctional services daily roster the official record of 
all staff assignments to the correctional services department. See 
appendix II for additional information on the correctional services 
daily rosters. 

[4] FCCs have two or more facilities colocated on a property that is 
contiguous. For purposes of this report we refer to both the FCCs and 
separate facilities as "facilities." 

[5] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[6] Some positions require certification or additional training. For 
example, the security officer position requires specific training 
courses in the repair and maintenance of BOP weapons and 
recertification every 2 to 3 years. 

[7] The labor-management relations chapter of title 5 of the U.S. Code 
permits BOP management to take whatever action is necessary to carry 
out the agency mission during emergencies. See 5 U.S.C. § 
7106(a)(2)(D). 

[8] GAO, Equal Employment Opportunity SSA Region X's Changes to Its EEO 
Process Illustrate Need for Agencywide Procedures, [hyperlink, 
http://www.gao.gov/products/GAO-03-604] (Washington, D.C.: July 16, 
2003). 

[9] GAO, Equal Employment Opportunity SSA Region X's Changes to Its EEO 
Process Illustrate Need for Agencywide Procedures, [hyperlink, 
http://www.gao.gov/products/GAO-03-604] (Washington, D.C.: July 16, 
2003). 

[10] EEOC's Management Directive 715 provides guidance and standards to 
federal agencies for establishing and maintaining effective equal 
employment opportunity programs, including a framework for executive 
branch agencies to help ensure effective management, accountability, 
and self-analysis. 

[11] We did not evaluate the policies and procedures of the other 
Justice law-enforcement components. 

[12] The centralized system is used regardless of whether or not there 
is an announced vacancy. 

[13] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). We used the criteria in these 
standards, issued pursuant to the requirements of the Federal Managers' 
Financial Integrity Act of 1982 (FMFIA), to provide the overall 
framework for establishing and maintaining internal control in the 
federal government. Pub. L. No. 97-255, 96 Stat. 814. Also pursuant to 
FMFIA, the Office of Management and Budget issued Circular No. A-123, 
revised December 21, 2004, to provide the specific requirements for 
assessing and reporting on internal controls. Internal control 
standards and the definition of internal control in Circular No. A-123 
are based on the aforementioned GAO standards. 

[14] The labor-management relations chapter of title 5 of the U.S. Code 
sets forth management's right to assign work and to determine the 
personnel by which operations shall be conducted. 5 U.S.C. § 
7106(a)(2)(B). 

[15] Staff assigned to the sick and annual list serve as a designated 
group of officers used for a variety of reasons including to fill in 
for staff on leave, in training, or for special assignments. The number 
of staff on the sick and annual list varies by facility. 

[16] BOP's computerized roster management system is a stand-alone 
Microsoft Access-based program used by each facility and contains 
information on all correctional services and non-correctional services 
staff who have previously been assigned a correctional services post or 
special assignment. 

[17] Some of the BOP captains we interviewed said they also reviewed 
roster summaries for overtime use and excused and unexcused absences. 
Officials from two of the facilities in our review said that their 
associate wardens review roster summaries including for the number of 
employees on leave and in training. 

[18] BOP's computerized system can generate an overtime report that 
includes for each day, the name of each staff member who worked 
overtime, the name of the post or type of special assignment, the hours 
worked by the staff member, and if the staff member was regularly 
assigned to a non-correctional services department. For non- 
correctional services staff, the summary on the last page of the daily 
roster contains a total count of the occurrences of non-correctional 
services staff used for mission critical posts and special assignments 
combined. 

[19] These officials said they are reviewing individual daily rosters 
for overall staffing, including use of sick and annual staff, 
correctional and non-correctional services staff, overtime, and special 
assignments. The officials also said that they are trying to make sure 
all staff (correctional services and non-correctional services) are 
assigned before overtime is used. 

[20] For mission critical posts, each estimate from these samples has a 
margin of error, at the 95 percent confidence level, of plus or minus 2 
percent or less for average daily percentage estimates or plus or minus 
2 posts or less for average daily post estimates. For special 
assignments, each estimate from these samples has a margin of error, at 
the 95 percent confidence level, of plus or minus 6 percent or less for 
average daily percentage estimates or plus or minus 3 special 
assignments or less for average daily special assignment estimates. 

[21] Temporary assignments are reflected on BOP facilities' 
correctional services daily rosters, which identify all individuals 
assigned to correctional services for the day and are generated using 
BOP's correctional services computerized roster management system. BOP 
considers the correctional services daily roster the official record of 
all staff assignments to the correctional services department. See 
appendix II for additional information on correctional services roster 
assignments. 

[22] FCCs have two or more facilities colocated on a property that is 
contiguous. For purposes of this report we refer to both the FCCs and 
separate facilities as "facilities." 

[23] NFC operates an integrated payroll/personnel system and provides 
related support services for the payroll process to various federal 
agencies. 

[24] Changes to leave categories can be made as needed after the daily 
roster has been finalized. The daily roster would be updated in the 
computerized roster management system and a new hard copy would be 
generated, signed, and stored at the facility. 

[25] One daily roster was excluded from our analysis because it was 
printed over 30 days after the date of the daily roster. 

[26] One roster from one facility and two rosters from another facility 
were excluded from our analysis because the rosters were either missing 
pages or were not provided to us. 

[27] The maximum daily posts were obtained from each facility's 
quarterly complement analysis which, according to BOP, is generated by 
each facility's computerized roster management system and shows which 
posts are to be staffed for the quarter as well as defining the 
staffing required to fill the listed posts for each day in that 
quarter. 

[28] The computerized roster management system is a stand-alone 
Microsoft Access-based program used by each facility and contains 
information on all correctional and non-correctional services staff who 
have previously been assigned a correctional services post or special 
assignment. The information is entered into each facility's 
computerized system at the facility level. 

[End of section] 

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